ML20027A631
| ML20027A631 | |
| Person / Time | |
|---|---|
| Site: | 05000000, San Onofre |
| Issue date: | 10/16/1980 |
| From: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Book H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20027A625 | List:
|
| References | |
| FOIA-82-394 NUDOCS 8011100459 | |
| Download: ML20027A631 (2) | |
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MEMORANDUM FOR:
H. E. Book, Chief, FFMS Branch, Region V FROM:
L. B. Higginbotham, As::istant Director, Division of Fuel Facility and Materials Safety Inspection, IE
SUBJECT:
SAN ON0FRE SHIPMENT IN NFS-4 CASK (NAC-lD)
AITS No.(H08000375F05)
Your October 9,1980 memo raised five questions concerning the above AITS item which we initiated by memo dated 9/17/80.
Our positions re the five questions are:
1.
We assume the data presented in Exhibit B does exceed the allowable criteria in the Certificate of Compliance. Based on an analysis of this data, NRC removed the cask from service on 9/5/80 and requested an amendment to the C of C by letter dated 9/12/80 (copy enclosed).
The data is being forwarded to NMSS for their assessment.
2.
The certification provided to San Onofre by NAC should be accepted.
This position is based on timely measurements and field analysis which indicated that measurements were within allowable criteria.
3.
As indicated in the amendment application, NAC became aware of the non-conformance in early September and took the cask out of service on 9/5/80.
4.
As indicated above, NAC notified the NRC of the nonconfonnance on 9/12/80.
5.
We do not support a citation for shipments in the NAC-10 cask which were made prior to 9/5/80.
If concompliance did occur, condition 14 of the license should be cited as the requirement.
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L. B. Hi i botham Assistant Director Division of Fuel Facility and Materials Safety Inspection, IE l
Enclosure:
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H. E.
Book OCT J f'r.CO cc:
C. E. MacDonald w/ copy of H. E. Book memo dated 10/9/80 CONTACT:
G. H. Bidinger 49-28188
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!!CMORA'iDU!! FOR:
L. B. liigginbotham, Assistant Director Division of Fuel Facility and ifaterials Safety Inspection, IE FR0!i:
H. E. Book, Chief Fuel Facility and Materials Safety Branch, Region V
SUBJECT:
Response to (AITS No. H08000375 FOS)
San Onofre Shipment in flFS-4 Cask (NAC-10)
On July 17, 1980 Southern California Edison Company (SCE) was advised by letter from their contractor, Nuclear Assurance Corporation (NAC) that the flFS-4 casks liAC-10 and IE had been assigned for use in the San Onofre Spent Fuel Shipping Program. A copy of that letter is attached as Exhibit A.
During the period August 19-21, 1980 representatives of NAC in the presence of SCE Quality Control personi.el performed the surveillance requirenent specified as condition 14 of Certificate of Compliance flo. 6698, Revision No.11 for the 10 Cask. A copy of the data collected is attached as Exhibit B.
Although SCE representatives were present during the surveillance, a copy of the acceptance criterion was not at the San Onofre site. Our inspector detemined the licensee had a copy of the June 8,1979 letter from Mr. J. D. Rollins, Vice President NAC to lir. C. E. MacDonald, Chief Transportation Branch at the corporate office located in Rosemead, California. From observation of the data collected it is not readily apparent that the specified criteria has been met.
Hearsay presented to our inspector indicates that difficulty was experienced by the ?!AC representatives in making a set of measurements that met the criteria during the first two attempts.
The third set of data apparently met the criteria and the f1AC office was informed by teleplene.
Cn August 22, 1980 SCE was notified in writing by PlAC that the NFS-4, NAC-10 cask was acceptable for use in accordance with C of C No. 6698, Revision 11.
A copy of that letter is attached as Exhibit C.
Based on the August 22, 1980 letter SCE loaded spent nuclear fuel in the 10 cask and shipped it to the General Electric Morris, Illinois facility on Septeder 4,1980.
On Septerber 9,1980 SCE received a copy of a September 5,1980 letter from LAC to General Electric informing them that the ID cask was being withdrawn from service.
A copy of this letter is attached at Exhibit D.
Based on discussions with licensee representatives during the week of i
Septerber 22-26, 1980 our inspector concluded SCE was not yet aware of the problem with respect to item 14 of the C of C.
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, lien 6 to 1.. B. Higgin$otham In order to pursue this matter from a regulatory point of view and consistent with protection of the public health and safety, Region V requests the following support:
1.
Does the data presented in Exhibit B exceed the allowable criteria of condition 14 of the C of C7 2.
If the criteria of condition 14 has been exceeded, what level of severity should be attached to this violation?
3.
When did NAC become aware of the possibility that the ID cask may 'not #
have been acceptable for use?
4.
When did iMC inform NRC the cask was not in confornance with the C of C7 5.
If the condition of the cask was such that the C of C was not complied with, shall the SCE be cited against 10 CFR 71.3?
Should you have additional questions regarding this natter an inspector will be at San Onofre October 14-17, 1980 and could assist you if necessary.
We would like to document this effort in Inspection Report No. 50-206/80-26.
It would be helpful if you could respond to our requests by October 24, 1980.
Thank you for your cooperation.
Original signed by H. E. Book H. E. Book, Chief Fuel Facility and !1aterials Safety Branch
Contact:
G. P. Yuha::
463-3743 Attachments:
1.
Exhibit A, letter NAC JMV/80/279/ETS, July 17, 1980 2.
Exhibit B, NAC 10 fleasurements Aug. 80, 5 pages 3.
Exhibit C, letter !!AC CRJ/80/135/ETS, August 22, 1980 4
Exhibit D, letter fMC Rk!C/80/21/ETS, September 9,1980 De